All in Regulatory Update

On December 10, 2025, the OCC released preliminary findings from its supervisory review of debanking activities at the nine largest national banks it supervises: JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank. The supervisory review was carried out by the OCC in accordance with the President’s Executive Order Guaranteeing Fair Banking for All Americans to assess if any institutions debanked or discriminated against customers based on their political or religious beliefs or lawful business activities.

On November 25, 2025, the FDIC announced that it is extending the compliance date for the requirements to display the FDIC official digital sign on an insured depository institution’s (IDI’s) digital deposit-taking channels and like devices from March 1, 2026, to January 1, 2027. The extension aligns the compliance date with the FDIC’s proposal issued earlier this year that would make adjustments to those provisions. 

On November 21, 2025, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT/CPF deficiencies. This advisory informs U.S. financial institutions about jurisdictions the Financial Action Task Force (FATF) has identified as having strategic deficiencies in their anti-money laundering, countering the financing of terrorism, and countering the financing of proliferation (AML/CFT/CPF) regimes.

On November 20, 2025, the Government Executive reported that the CFPB will furlough much of its workforce on December 31, 2025, and transfer its remaining litigation and enforcement cases to the DOJ. This development follows the administration’s decision to stop drawing funds from the Federal Reserve, the statutory mechanism that has historically supported the bureau’s operations.